|
Highlights
MUTUAL FUND TRUSTS
Recent Proposals Dealing With Canadian Mutual Fund Trusts
With Non-resident Beneficiaries
Peter Jovicic
Amendments to the Income Tax Act proposed in draft
legislation introduced on September 16, 2004, will impose a tax on gains
on taxable Canadian property realized by mutual fund trusts and mutual
fund corporations when these gains are distributed to non-residents.
Peter Jovicic examines the policy and mechanics of the proposed new tax,
observing that it is in keeping with the policy underlying the tax
imposed under Part XII.2 on other trusts with non-resident
beneficiaries.
TRUSTS
Shifting Income to Low-tax Provinces
Wolfe D. Goodman
Dr. Goodman discusses a recent article by David A.
Sohmer of Spiegel Sohmer in Montreal, in which Mr. Sohmer describes the
recent efforts of the government of Quebec to address certain planning
techniques that shift income to lower tax provinces in Canada. The
planning of concern to the government of Quebec uses the tax residence
of trusts to provide favourable tax results in regard to dividend and
other investment income. Dr. Goodman advises that Mr. Sohmer's article
will be of interest to planners outside as well as inside Quebec.
TRUSTS
Preserving an Equitable Balance Between Income and Capital
Beneficiaries
Wolfe D. Goodman
CHARITABLE DONATIONS
Tax Issues to Consider When a Taxpayer Makes a Charitable
Donation Through a Will or Trust
Ryan Lay
Ryan Lay considers at length the issues relating to
the timing and source of charitable donations. The author summarizes two
recent articles by Kathy Munro and Elena Hoffstein in the Fall 2004
Step Inside newsletter.
VALUATION
Art Collection – Charitable Deduction Under IRS
Section 2055
Wolfe D. Goodman
CHARITIES
Proposed Tax Rules Applicable to Charities
Wolfe D. Goodman
CHARITIES
Municipal Property Tax Exemptions
Wolfe D. Goodman
INCOME TAX
U.S. Virgin Islands – Conflict With U.S. Taxation
Wolfe D. Goodman
SINGLE PURPOSE CORPORATIONS
Single Purpose Corporations Limited for U.S. Estate
Planning
Martin J. Rochwerg
U.S. ESTATE TAX
Domicile as a Basis of U.S. Estate Tax
Wolfe D. Goodman
COMPANY RESIDENCE
Residence of a Company – U.K. Decision
Wolfe D. Goodman
VALUATION
Premium for Smaller Businesses
Wolfe D. Goodman
| |
Board
Dr. Wolfe D. Goodman, QC, SJD
Editor-in-Chief
Goodman and Carr LLP
Elisabeth Atsaidis
Goodman and Carr LLP
Paul Bleiwas
Goodman and Carr LLP
D. Bernard Morris
Goodman and Carr LLP
David P. Stevens
Goodman and Carr LLP
Clare A. Sullivan
Goodman and Carr LLP
Martin J. Rochwerg
Goodman and Carr LLP
Janine A.S. Thomas
Goodman and Carr LLP |
